Bycatch Review Task Force comment

Alaska Bycatch Task Force – Public Comment from the Alaska Marine Conservation Council, 10-18-22


Good Morning,


Theresa Peterson speaking on behalf of the Alaska Marine Conservation Council. Thank you for the opportunity to speak today and I want to compliment the work done by the task force and the committees. You have before you a comprehensive list of research and management recommendations which are responsive to the charge of the task force and input from the public.


I see all the committees recommended the need to update the assumed discard mortality for all gear groups, this is consistent with what I have heard in the Council arena and we support this.


I do think it will be important to prioritize the research recommendations based on stock status for species currently under collapse such as Bering Sea crab and Western Alaska chinook and salmon stocks.


For salmon, research to improve our ability to determine the stock of origin for chum and Chinook salmon taken as bycatch is critical along with an understanding of the increased value of an adult spawner to a river system. For example, as returns decline in Western Alaska each returning salmon carries a weight of importance which has changed since the bycatch limits for Chinook in the pollock fleet were put in place.


For crab, research is needed to address observed and unobserved mortality caused by gear interactions. With the current status of the Bering Sea crab stocks I see this as a longer process with some immediate management recommendations needed as the research process develops.


In terms of GOA Tanner crab, which is doing well with expectations that Kodiak harvest will surpass that of the Bering Sea, I do see merit in full retention of crab in trawl fisheries for a period of two years. With limited observer coverage in the GOA we have little understanding of the interactions with trawl gear and the species composition of the bycaught crab. It would be a process to work through the logistical challenges of full retention but I think it merits consideration.


I’ll segway to management recommendations and start with support for the recommendation to require 100% observer coverage on all Gulf of Alaska non-pelagic trawl catcher vessels, which would also be key if full retention is advanced.


The trawl fleet has made tremendous strides with EM on pelagic fisheries targeting pollock and EM systems are in place on gulf trawl vessels which participate in pelagic and non pelagic trawling.


It is important to get increased observer data prior to rationalizing the trawl fisheries.


Rationalizing is recognized as a means to reduce bycatch but it is important to have adequate data to understand what the interactions are to reduce from prior to moving the discussion forward.


The recent rationalization of the CV trawl sector in the Bering Sea was informed by 100% observer coverage which led to an understanding of what could be achieved when coupled with the voluntary catch share programs the fleet was operating under.

The flexibility of the partial coverage observer program should allow this. All sectors benefit from data and intensifying coverage in the trawl fleet for a period of time and modification of the sampling design to achieve this is in line with what stakeholders understood the program was designed to do. The same fee structure across all sectors provides an important revenue source that does not increase individual vessel cost.


There have been long standing concerns that the current Gulf of Alaska partial coverage observer program is not adequate to understand prohibited Species Catch (PSC) interactions in high volume trawl fisheries to inform PSC usage and potential PSC savings.


As conditions in the GOA change, increased data is critical to be responsive to stakeholder concerns and increase public confidence in the restructured program with increased accountability of PSC in the trawl sector. accurate data on bycatch is even more important now than it was when the Council took final action on the observer program in 2012.

Interactions with salmon, sablefish, halibut and Tanner crab remain a concern along with concern of the impacts to those who fish directly for these species.


After multiple attempts by the Council and the trawl fleet to develop a program which makes it across the finish line, perhaps increased confidence in PSC usage could help garner greater support.


Groundfish fisheries which may be rationalized are a common use resource in the Gulf of Alaska which is a region surrounded by fishing communities dependent on the health of the GOA fisheries for their livelihoods. Increased coverage for a period to inform a potential new management program is a relatively small ask in the scope of things.


This would also help inform another recommendation, Review and consider revising open and closed areas for bottom trawl in the Gulf of Alaska. There are areas in the east side of Kodiak in the stat areas we referenced in our previously submitted comments which are critical to Tanner crab populations. The interactions of trawl gear in these areas must be understood to support the health of this population and the resulting fishery that is so important to the state managed fishery.


Another recommendation which I believe should apply to both the GOA and Bering Sea is to consider revising the pelagic gear definition to limit bottom contact.

It is critical that we understand the time on the bottom of pelagic trawls in areas closed to bottom trawling and factor in the associated habitat and unobserved mortality impacts. There is increased understanding of the time on the bottom of pelagic gear and we must address this.


We are currently facing critically low abundance of Bering sea crab stocks in Alaskan waters, we need to start assessing habitat disturbance for its impacts on the ecosystem as a whole, particularly in areas like the red king crab savings area which are closed to bottom trawling to protect habitat and reduce mortality. Disturbance of habitat can affect all the species down to the smallest of feed organisms.


Ongoing harvest of other target species such as pollock in areas closed to bottom trawling areas prioritizes that harvest opportunity over the critical conservation benefits of prioritizing this habitat for struggling species like crab which depend on the integrity of ocean biodiversity inextricably linked to intact, healthy habitat, a critical tool of resilience in the ocean.


And last but not least, the State should work to establish a scientific-based chum salmon cap to reduce bycatch of Western Alaska salmon in the pollock fishery in the Bering Sea. A discussion paper is coming before the NP Council in December along with a review of the recommendations of the task force. Western Alaska subsistence needs are suffering in a way few of us can understand. Limits need to be put in place to control chum bycatch.




Theresa Peterson,

Fisheries Policy Director



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